Filings, Letters and Testimonies

INGAA submits comments and filings to various regulatory, congressional and administrative entities. You can search by year, agency, and title using the search engine below. Also, the most recent submissions are highlighted on the home page and appear in chronological order below the search engine.

The Interstate Natural Gas Association of America (INGAA), a trade association that represents members of the interstate natural gas pipeline industry, respectfully submits these comments in response to the United States Environmental Protection Agency’s (EPA’s) request for input on ...

The ESA Cross-Industry Coalition is pleased to provide the unified position of a major portion of our nation’s economic sectors on three proposals from the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) (together, the Services) to amend their Endangered ...

The Interstate Natural Gas Association of America (“INGAA”) and the American Gas Association (“AGA”) respectfully submit these comments in response to the Council on Environmental Quality’s (“CEQ”) request for comment on potential revisions to its ...

The Interstate Natural Gas Association of America (“INGAA”) submits these comments in response to the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) notice of inquiry (“NOI”) on its currently effective policy statement1 on the ...

INGAA responds to the argument made by commenters that the elimination of a tax allowance for MLPs and potentially other pass-through entities must result in the expeditious return of excess ADIT to customers of such pipelines. For the reasons stated in INGAA’s comments, ADIT issues ...

On February 17, 2017, November 20, 2017 and March 2, 2018, the Associations, along with the American Public Gas Association, filed comments relating to PHMSA’s Pipeline Safety: Safety of Underground Natural Gas Storage Facilities Interim Final Rule (Docket No. PHMSA-2016-0016). The ...

On December 22, 2017, the President signed the Tax Cut and Jobs Act (“TCJA”) into law, which reduced the federal corporate income tax rate from 35 percent to 21 percent, effective January 1, 2018. Additionally, as pertinent to these comments, the TCJA prohibited the use of bonus ...

The Interstate Natural Gas Association of America (“INGAA”) respectfully submits these comments in response to the U.S. Environmental Protection Agency’s (“EPA’s”) request for comments on the Information Collection Request (“ICR”) ...

A few commenters request the Commission to clarify that negotiated rate contracts are subject to revision and allow rate reductions for shippers under such contracts. Indicated Shippers argue that the Commission should allow negotiated rate shippers to share in the tax cost reductions ...

AGA and INGAA are petitioning PHMSA to amend 49 CFR Part 193.2619 to recognize and enforce the pressure relief device (PRD) testing requirements in NFPA 59A (2001 edition) at 11.5.5.1(e) (incorporated by reference in 49 CFR Part 193) instead of the current requirements in 49 CFR Part ...

INGAA supports the Commission’s continued examination of grid reliability and resilience in regional transmission organizations (“RTOs”) and independent system operators (“ISOs”). Every RTO and ISO, including PJM, plays a crucial role in ensuring a reliable ...

INGAA appreciates the Commission’s efforts to chart a path forward to address the TCJA’s reduction in corporate income tax rates in a manner that is generally consistent with the ratemaking requirements of Sections 4 and 5 of the Natural Gas Act. The NOPR generally conforms to the ...

INGAA requests that the Commission grant rehearing or reconsider its conclusion that INGAA and other commenters failed to demonstrate that MLPs will not double recover income taxes if they continue to be provided with a tax allowance. INGAA further requests that the Commission clarify that, ...

The American Gas Association (“AGA”) and the Interstate Natural Gas Association of America (“INGAA”) respectfully submit these comments in response to the United States Army Corps of Engineers’ (the “Corps’”) public notice ...